Preview
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
BRISTOL, ss. CIVIL ACTION NO. 2273CV00266
oe verte si
ABIJAH JONES,
Plaintiff,
Vv.
LIFE CARE CENTERS OF AMERICA, )
INC,; and PATRICK O’CONNOR, )
individually and as Executive Director of Life )
Care Centers of America, Inc.; and DOREEN )
ROBINSON, individually and as Director of )
Nursing of Life Care Centers of America, Inc. )
)
Defendants. )
cern ee co — )
JOINT MOTION FOR COURT APPROVAL OF
CONFIDENTIALITY AGREEMENT AND ORDER
The Plaintiff Abijah Jones and Defendants, Life Care Centers of America, Inc., Patrick
O’Connor, and Doreen Robinson, hereby jointly move this Court to approve and issue the
Confidentiality Agreement and Order attached hereto as Exhibit 1. As grounds for this joint
motion, the parties state as follows:
1 In his Complaint, Plaintiff has alleged that Defendants unlawfully discriminating and
retaliating against him, in violation of the M.G.L. c. 151B, §§ 4(4), 4(4A) and 4(16), on
the basis of him taking leave while he was sick and symptomatic with COVID-19, for
creating a hostile work environment, and also for retaliation. Plaintiff has also alleged
that Defendants engaged in actions which were in violation of the Family Medical Leave
Act.
103295040
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
2. The Defendants deny any wrongdoing and that they otherwise took any actions in
violation of the law.
Plaintiff served requests for production of documents, which, in part, seek documents that
Defendants have asserted contain confidential information, which should be subject to
reasonable protections against disclosure outside of this litigation.
The provisions of the proposed Confidentiality Agreement and Order submitted herein
have been agreed to by the parties and will facilitate their orderly exchange of discovery
information while guarding against any improper use of confidential information.
WHEREFORE, the parties jointly request that the Court enter the Confidentiality
Agreement and Order in the form submitted with this motion.
Respectfully submitted,
Plaintiff, Defendant,
ABIJAH JONES, LIFE CARE CENTERS OF AMERICA,
INC., PATRICK O’CONNOR, and
By His Attorneys DOREEN ROBINSON,
By Their Attorneys,
/s/ Catherine B. Kramer
/s/ Edwin F. Landers, Jr.
Scott W. Lang, Esq. BBO# 285720 _
swlang@Ixblaw.com
Swia Edwin F. Landers,
Jr., Esq. BBO# 559360
Catherine B. Kramer, Esq. BBO# 684876 elanders@morrisonmahoney.com
cbkramer@|xblaw.com Tan T. Donovan, sq. BBO# 703377
Lang, Xifaras & Bullard idonovan@morrisonmahoney.com
115 Orchard Street Morrison Mahoney LLP
New Bedford, MA 02740 250 Summer Street
Tel: (508) 992-11270 Boston, MA 02210
Tel: (617) 439-7500
103295040
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
CERTIFICATE
tN EAL OF SERIE
SERVICE
I, Ian Donovan, hereby certify that a true and accurate copy of the foregoing document
was served via email on January 12, 2024, upon ail counsel of record:
Scott W. Lang, Esq. BBO# 285720
swlang@|xblaw.com
Catherine B. Kramer, Esq. BBO# 684876
cbkramer@l:
Lang, ifara:
115 Orchard Street
New Bedford, MA 02740
Tel: (508) 992-11270
/s/ Tan Donovan
tennant
Tan Donovan
103295040
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
BRISTOL, ss. CIVIL ACTION NO. 2273CV00266
enna tenn
ABIJAH JONES,
Plaintiff,
Vv.
LIFE CARE CENTERS OF AMERICA, )
INC.; and PATRICK O’CONNOR, )
individually and as Executive Director of Life )
Care Centers of America, Inc.; and DOREEN )
ROBINSON, individually and as Director of |)
Nursing of Life Care Centers of America, Inc. )
)
Defendants. )
a a a o - )
NON-DISCLOSURE AGREEMENT
L ~ ne _, being duly sworn, hereby depose and say as follows:
1 I reside at _ a ~ fo ween
~ (street address)
~ > — _ 1 am employed by a ~
~ Gityor town) (state)
in the position of — ~
2 I have read and understand the provisions of the Confidentiality Agreement in
connection with the action pending before the Bristol County Superior Court, captioned Abijah
Jones v. Life Care Centers of America, Inc., et al., Civil Action Number 2273CV00266. I agree
to be bound by the terms of such Confidentiality Agreement and to maintain the confidentiality of
4
103295040
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
information and/or documents designated “Confidential” under the terms of the Confidentiality
Agreement.
3 Thereby submit to the jurisdiction of the Bristol Superior Court for the purpose of
enforcing said Confidentiality Agreement and this Non-Disclosure Agreement.
SIGNED UNDER THE PENALTIES OF PERJURY THIS em DAY OF
202__
wean
—
Printed Name
103295040
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
EXHIBIT 1
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
BRISTOL, ss. CIVIL ACTION NO. 2273CV00266
-
ABIJAH JONES,
Plaintiff,
Vv.
LIFE CARE CENTERS OF AMERICA, )
INC.; and PATRICK O’CONNOR,, )
individually and as Executive Director of Life )
Care Centers of America, Inc.; and DOREEN )
ROBINSON, individually and as Director of )
Nursing of Life Care Centers of America, Inc. )
Defendants.
es
CONFIDENTIALITY AGREEMENT AND ORDER
In order to preserve the confidentiality of all documents relating to non-public or
proprietary business information that may be produced by the parties in connection with the above-
captioned action entitled Abijah Jones v. Life Care Centers of America, Inc., et al., Civil Action
Number 2273CV00266, pending before the Bristol County Superior Court (the “Action”), the
plaintiff, Abijah Jones, and the defendants, Life Care Centers of America, Inc., Patrick O’Connor,
and Doreen Robinson, (hereinafter “the Parties”) acting by and through their representatives,
hereby agree as follows:
1 This Confidentiality Agreement shall govern the confidentiality, disclosure and use
of documents relating to any and all non-public or proprietary business information produced by
the Parties in the Action.
2 All documents relating to non-public or proprietary business information produced
by the Parties are deemed to be confidential to the extent so designated by a party as “Confidential”
(the “Confidential Documents”).
3 Inadvertent failure to designate documents as Confidential at the time of production
may be remedied by supplemental written notice. If such notice is given, all documents so
designated shall be fully subject to this Confidentiality Agreement as if they had been initially
103334230
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
designated as Confidential. Duplicates of a document designated by a party as “Confidential” shall
be deemed to be confidential without the necessity of designating the duplicates as “Confidential.”
4 Nothing herein shall preclude the Parties from contesting in good faith, by motion
or otherwise, and upon notice to the opposing party, the confidentiality of any document produced
by a party in the Action. Prior to filing any such motion, the Parties shall endeavor to resolve all
disputes as to confidentiality on an informal basis.
5 Except as expressly agreed by the Parties with respect to specified documents, the
Parties shall not disclose and/or use any Confidential Document except as provided by this
Confidentiality Agreement.
6 Confidential documents may be used by the parties and others with whom the
parties share the confidential documents pursuant to the terms of this Confidentiality Agreement
in connection with this action for all discovery purposes, pre-trial motions, and at the trial as
documentary evidence for all purposes, including impeachment, to the same extent as if said
document had not been identified as confidential and for no other purpose. At the trial or any other
proceeding in which the document is referenced or any contents thereof is identified in open court,
the introduction of the document and/or references to its contents shall be made only subject to
such safeguards and other reasonable conditions as ordered by the trial judge in an order sought
by any party in a motion in limine.
7 Except as may otherwise be required by law, Confidential Documents may not be
disclosed by the Parties to any person other than their representative or any independent expert,
consultant, or similar person who has been retained by the Parties’ respective representative to
provide assistance, expert advice, or testimony in the Action, provided that any such independent
expert, consultant, or similar person to whom any Confidential Document is disclosed pursuant to
the above, shall, prior to any such disclosure, be provided with a copy of this Confidentiality
Agreement and execute the “Nondisclosure Agreement” in the form attached hereto. No person
to whom Confidential Documents are disclosed pursuant to the provisions of this paragraph shall
disclose Confidential Documents to any person not entitled to receive such Confidential
Documents under the terms of this Confidentiality Agreement.
8 At the conclusion of this action, the Parties shall return to the producing party all
Confidential Documents produced in the action, and all copies of such Confidential Documents
caused or permitted to be made, or destroy all such Confidential Documents, including copies,
unless otherwise required by law.
9 Any attorney-client privileged document that is inadvertently produced shall be
returned to the producing party, in accordance with Massachusetts law.
10. Nothing agreed herein shall constitute a waiver or limitation of a party’s right to
object to and/or withhold from production or disclosure any fact or document as provided by law.
103334230
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
Respectfully submitted,
Plaintiff, Defendant,
ABIJAH JONES, LIFE CARE CENTERS OF AMERICA,
INC., PATRICK O’CONNOR, and
By His Attorneys DOREEN ROBINSON,
By Their Attorneys,
/s/ Catherine B. Kramer
eer no /s/ Edwin F. Landers, Jr.
Scott W. Lang, Esq. BBO# 285720 a
swlang@Ixblaw.com Ed anders, Jr., Esq. BBO# 559360
Catherine B, Kramer, Esq. BBO# 684876 elanders@morrisonmahoney.com
cbkramer@|xblaw.com
aw .COl Ian T. Donovan, Esq. BBO# 703377
Lang, Xifaras & Bullard ey.com
om
115 Orchard Street
New Bedford, MA 02740 250 Summer Street
Tel: (508) 992-11270 Boston, MA 02210
Tel: (617) 439-7500
SO ORDERED:
Justice
of the Superior Court —
103334230
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
CERTIFICATE OF SERVICE
I, Jan Donovan, hereby certify that a true and accurate copy of the foregoing document
was served via email on January 12, 2024, upon all counsel of record:
Scott W. Lang, Esq. BBO# 285720
swlang@|xblaw.com
wha
Catherine B. Kramer, Esq. BBO# 684876
cbkramer@Ixblaw,
Lang, Xifaras & B ard
115 Orchard Street
New Bedford, MA 02740
Tel: (508) 992-11270
/s/ Jan Donovan
see
Tan Donovan
103334230
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
BRISTOL, ss. CIVIL ACTION NO. 2273CV00266
—
ABIJAH JONES,
Plaintiff,
Vv.
LIFE CARE CENTERS OF AMERICA, )
INC.; and PATRICK O’CONNOR, )
individually and as Executive Director of Life )
Care Centers of America, Inc.; and DOREEN )
ROBINSON, individually and as Director of )
Nursing of Life Care Centers of America, Inc. )
Defendants.
se ewe ese a
NON-DISCLOSURE AGREEMENT
1 ~ oo _» being duly sworn, hereby depose and say as follows:
1 I reside at _ a a
"(street address) —
cece a o’ a owe! I am employed by eer
(city or town) ~ (state)
in the position of
2 I have read and understand the provisions of the Confidentiality Agreement in
connection with the action pending before the Bristol County Superior Court, captioned Abijah
Jones y, Life Care Centers of America, Inc., et al., Civil Action Number 2273CV00266. I agree
to be bound by the terms of such Confidentiality Agreement and to maintain the confidentiality of
5
103334230
Date Filed 1/12/2024 11:23 AM
Superior Court - Bristol
Docket Number 2273CV00266
information and/or documents designated “Confidential” under the terms of the Confidentiality
Agreement.
3 I hereby submit to the jurisdiction of the Bristol Superior Court for the purpose of
enforcing said Confidentiality Agreement and this Non-Disclosure Agreement.
SIGNED UNDER THE PENALTIES OF PERJURY THIS _ _DAY
OF _ re
202
oe aoe aoe
co ova
Printed Name
103334230
Preview
Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT BRISTOL, ss. CIVIL ACTION NO. 2273CV00266 oe verte si ABIJAH JONES, Plaintiff, Vv. LIFE CARE CENTERS OF AMERICA, ) INC,; and PATRICK O’CONNOR, ) individually and as Executive Director of Life ) Care Centers of America, Inc.; and DOREEN ) ROBINSON, individually and as Director of ) Nursing of Life Care Centers of America, Inc. ) ) Defendants. ) cern ee co — ) JOINT MOTION FOR COURT APPROVAL OF CONFIDENTIALITY AGREEMENT AND ORDER The Plaintiff Abijah Jones and Defendants, Life Care Centers of America, Inc., Patrick O’Connor, and Doreen Robinson, hereby jointly move this Court to approve and issue the Confidentiality Agreement and Order attached hereto as Exhibit 1. As grounds for this joint motion, the parties state as follows: 1 In his Complaint, Plaintiff has alleged that Defendants unlawfully discriminating and retaliating against him, in violation of the M.G.L. c. 151B, §§ 4(4), 4(4A) and 4(16), on the basis of him taking leave while he was sick and symptomatic with COVID-19, for creating a hostile work environment, and also for retaliation. Plaintiff has also alleged that Defendants engaged in actions which were in violation of the Family Medical Leave Act. 103295040 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 2. The Defendants deny any wrongdoing and that they otherwise took any actions in violation of the law. Plaintiff served requests for production of documents, which, in part, seek documents that Defendants have asserted contain confidential information, which should be subject to reasonable protections against disclosure outside of this litigation. The provisions of the proposed Confidentiality Agreement and Order submitted herein have been agreed to by the parties and will facilitate their orderly exchange of discovery information while guarding against any improper use of confidential information. WHEREFORE, the parties jointly request that the Court enter the Confidentiality Agreement and Order in the form submitted with this motion. Respectfully submitted, Plaintiff, Defendant, ABIJAH JONES, LIFE CARE CENTERS OF AMERICA, INC., PATRICK O’CONNOR, and By His Attorneys DOREEN ROBINSON, By Their Attorneys, /s/ Catherine B. Kramer /s/ Edwin F. Landers, Jr. Scott W. Lang, Esq. BBO# 285720 _ swlang@Ixblaw.com Swia Edwin F. Landers, Jr., Esq. BBO# 559360 Catherine B. Kramer, Esq. BBO# 684876 elanders@morrisonmahoney.com cbkramer@|xblaw.com Tan T. Donovan, sq. BBO# 703377 Lang, Xifaras & Bullard idonovan@morrisonmahoney.com 115 Orchard Street Morrison Mahoney LLP New Bedford, MA 02740 250 Summer Street Tel: (508) 992-11270 Boston, MA 02210 Tel: (617) 439-7500 103295040 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 CERTIFICATE tN EAL OF SERIE SERVICE I, Ian Donovan, hereby certify that a true and accurate copy of the foregoing document was served via email on January 12, 2024, upon ail counsel of record: Scott W. Lang, Esq. BBO# 285720 swlang@|xblaw.com Catherine B. Kramer, Esq. BBO# 684876 cbkramer@l: Lang, ifara: 115 Orchard Street New Bedford, MA 02740 Tel: (508) 992-11270 /s/ Tan Donovan tennant Tan Donovan 103295040 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT BRISTOL, ss. CIVIL ACTION NO. 2273CV00266 enna tenn ABIJAH JONES, Plaintiff, Vv. LIFE CARE CENTERS OF AMERICA, ) INC.; and PATRICK O’CONNOR, ) individually and as Executive Director of Life ) Care Centers of America, Inc.; and DOREEN ) ROBINSON, individually and as Director of |) Nursing of Life Care Centers of America, Inc. ) ) Defendants. ) a a a o - ) NON-DISCLOSURE AGREEMENT L ~ ne _, being duly sworn, hereby depose and say as follows: 1 I reside at _ a ~ fo ween ~ (street address) ~ > — _ 1 am employed by a ~ ~ Gityor town) (state) in the position of — ~ 2 I have read and understand the provisions of the Confidentiality Agreement in connection with the action pending before the Bristol County Superior Court, captioned Abijah Jones v. Life Care Centers of America, Inc., et al., Civil Action Number 2273CV00266. I agree to be bound by the terms of such Confidentiality Agreement and to maintain the confidentiality of 4 103295040 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 information and/or documents designated “Confidential” under the terms of the Confidentiality Agreement. 3 Thereby submit to the jurisdiction of the Bristol Superior Court for the purpose of enforcing said Confidentiality Agreement and this Non-Disclosure Agreement. SIGNED UNDER THE PENALTIES OF PERJURY THIS em DAY OF 202__ wean — Printed Name 103295040 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 EXHIBIT 1 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT BRISTOL, ss. CIVIL ACTION NO. 2273CV00266 - ABIJAH JONES, Plaintiff, Vv. LIFE CARE CENTERS OF AMERICA, ) INC.; and PATRICK O’CONNOR,, ) individually and as Executive Director of Life ) Care Centers of America, Inc.; and DOREEN ) ROBINSON, individually and as Director of ) Nursing of Life Care Centers of America, Inc. ) Defendants. es CONFIDENTIALITY AGREEMENT AND ORDER In order to preserve the confidentiality of all documents relating to non-public or proprietary business information that may be produced by the parties in connection with the above- captioned action entitled Abijah Jones v. Life Care Centers of America, Inc., et al., Civil Action Number 2273CV00266, pending before the Bristol County Superior Court (the “Action”), the plaintiff, Abijah Jones, and the defendants, Life Care Centers of America, Inc., Patrick O’Connor, and Doreen Robinson, (hereinafter “the Parties”) acting by and through their representatives, hereby agree as follows: 1 This Confidentiality Agreement shall govern the confidentiality, disclosure and use of documents relating to any and all non-public or proprietary business information produced by the Parties in the Action. 2 All documents relating to non-public or proprietary business information produced by the Parties are deemed to be confidential to the extent so designated by a party as “Confidential” (the “Confidential Documents”). 3 Inadvertent failure to designate documents as Confidential at the time of production may be remedied by supplemental written notice. If such notice is given, all documents so designated shall be fully subject to this Confidentiality Agreement as if they had been initially 103334230 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 designated as Confidential. Duplicates of a document designated by a party as “Confidential” shall be deemed to be confidential without the necessity of designating the duplicates as “Confidential.” 4 Nothing herein shall preclude the Parties from contesting in good faith, by motion or otherwise, and upon notice to the opposing party, the confidentiality of any document produced by a party in the Action. Prior to filing any such motion, the Parties shall endeavor to resolve all disputes as to confidentiality on an informal basis. 5 Except as expressly agreed by the Parties with respect to specified documents, the Parties shall not disclose and/or use any Confidential Document except as provided by this Confidentiality Agreement. 6 Confidential documents may be used by the parties and others with whom the parties share the confidential documents pursuant to the terms of this Confidentiality Agreement in connection with this action for all discovery purposes, pre-trial motions, and at the trial as documentary evidence for all purposes, including impeachment, to the same extent as if said document had not been identified as confidential and for no other purpose. At the trial or any other proceeding in which the document is referenced or any contents thereof is identified in open court, the introduction of the document and/or references to its contents shall be made only subject to such safeguards and other reasonable conditions as ordered by the trial judge in an order sought by any party in a motion in limine. 7 Except as may otherwise be required by law, Confidential Documents may not be disclosed by the Parties to any person other than their representative or any independent expert, consultant, or similar person who has been retained by the Parties’ respective representative to provide assistance, expert advice, or testimony in the Action, provided that any such independent expert, consultant, or similar person to whom any Confidential Document is disclosed pursuant to the above, shall, prior to any such disclosure, be provided with a copy of this Confidentiality Agreement and execute the “Nondisclosure Agreement” in the form attached hereto. No person to whom Confidential Documents are disclosed pursuant to the provisions of this paragraph shall disclose Confidential Documents to any person not entitled to receive such Confidential Documents under the terms of this Confidentiality Agreement. 8 At the conclusion of this action, the Parties shall return to the producing party all Confidential Documents produced in the action, and all copies of such Confidential Documents caused or permitted to be made, or destroy all such Confidential Documents, including copies, unless otherwise required by law. 9 Any attorney-client privileged document that is inadvertently produced shall be returned to the producing party, in accordance with Massachusetts law. 10. Nothing agreed herein shall constitute a waiver or limitation of a party’s right to object to and/or withhold from production or disclosure any fact or document as provided by law. 103334230 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 Respectfully submitted, Plaintiff, Defendant, ABIJAH JONES, LIFE CARE CENTERS OF AMERICA, INC., PATRICK O’CONNOR, and By His Attorneys DOREEN ROBINSON, By Their Attorneys, /s/ Catherine B. Kramer eer no /s/ Edwin F. Landers, Jr. Scott W. Lang, Esq. BBO# 285720 a swlang@Ixblaw.com Ed anders, Jr., Esq. BBO# 559360 Catherine B, Kramer, Esq. BBO# 684876 elanders@morrisonmahoney.com cbkramer@|xblaw.com aw .COl Ian T. Donovan, Esq. BBO# 703377 Lang, Xifaras & Bullard ey.com om 115 Orchard Street New Bedford, MA 02740 250 Summer Street Tel: (508) 992-11270 Boston, MA 02210 Tel: (617) 439-7500 SO ORDERED: Justice of the Superior Court — 103334230 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 CERTIFICATE OF SERVICE I, Jan Donovan, hereby certify that a true and accurate copy of the foregoing document was served via email on January 12, 2024, upon all counsel of record: Scott W. Lang, Esq. BBO# 285720 swlang@|xblaw.com wha Catherine B. Kramer, Esq. BBO# 684876 cbkramer@Ixblaw, Lang, Xifaras & B ard 115 Orchard Street New Bedford, MA 02740 Tel: (508) 992-11270 /s/ Jan Donovan see Tan Donovan 103334230 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT BRISTOL, ss. CIVIL ACTION NO. 2273CV00266 — ABIJAH JONES, Plaintiff, Vv. LIFE CARE CENTERS OF AMERICA, ) INC.; and PATRICK O’CONNOR, ) individually and as Executive Director of Life ) Care Centers of America, Inc.; and DOREEN ) ROBINSON, individually and as Director of ) Nursing of Life Care Centers of America, Inc. ) Defendants. se ewe ese a NON-DISCLOSURE AGREEMENT 1 ~ oo _» being duly sworn, hereby depose and say as follows: 1 I reside at _ a a "(street address) — cece a o’ a owe! I am employed by eer (city or town) ~ (state) in the position of 2 I have read and understand the provisions of the Confidentiality Agreement in connection with the action pending before the Bristol County Superior Court, captioned Abijah Jones y, Life Care Centers of America, Inc., et al., Civil Action Number 2273CV00266. I agree to be bound by the terms of such Confidentiality Agreement and to maintain the confidentiality of 5 103334230 Date Filed 1/12/2024 11:23 AM Superior Court - Bristol Docket Number 2273CV00266 information and/or documents designated “Confidential” under the terms of the Confidentiality Agreement. 3 I hereby submit to the jurisdiction of the Bristol Superior Court for the purpose of enforcing said Confidentiality Agreement and this Non-Disclosure Agreement. SIGNED UNDER THE PENALTIES OF PERJURY THIS _ _DAY OF _ re 202 oe aoe aoe co ova Printed Name 103334230